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CITY OF VANCOUVER ADMINISTRATIVE REPORT |
Date: |
December 13, 2004 | |
Author: |
Chris Baber, P.Eng. | |
Phone No.: |
604-871-6127 | |
RTS No.: |
04762 | |
CC File No.: |
3753 | |
Meeting Date: |
January 18, 2005 |
TO: |
Vancouver City Council |
FROM: |
General Manager of Engineering Services |
SUBJECT: |
New Health Canada Draft Water Quality Guidelines |
RECOMMENDATION
That the Mayor, on behalf of City Council, send a letter to the Provincial Minister of Health Services and the Federal-Provincial-Territorial Committee on Drinking Water on the new Health Canada draft Water Quality Guideline documents relating to Microbiological Quality and Trihalomethanes, as outlined in this report.
GENERAL MANAGER'S COMMENTS
The General Manager of Engineering Services recommends approval of the foregoing.
COUNCIL POLICY
All letters to Provincial Ministers arising from Council actions are to be signed by the Mayor.
PURPOSE
This report provides comments on the new Health Canada draft water quality guideline documents and recommends that these comments be conveyed to the Provincial Minister of Health and the Federal-Provincial-Territorial Committee on Drinking Water.
BACKGROUND
Health Canada and the Federal-Provincial-Territorial Committee on Drinking Water released new draft water quality guideline documents in August and have asked for public comment. Health Canada and the Federal-Provincial-Territorial Committee have indicated they will then revise the documents following evaluation of comments received, and the revised guidelines will become part of the Guidelines for Canadian Drinking Water Quality. The Guidelines have no regulatory standing in British Columbia, as the Provincial Government has the authority to regulate drinking water. However, historically the Province and the local Medical Health Officers have considered the Guidelines for Canadian Drinking Water Quality in developing and administering regulatory standards.
On October 29, 2004, the GVWD Water Board approved staff recommendations to authorize the Board Chair to comment on the draft water quality guidelines. Also approved was a recommendation to encourage GVWD member municipalities to provide their comments on the draft guidelines.
DISCUSSION
The key comments on the new Health Canada Guidelines are summarized below.
Microbiological Quality of Drinking Water
The background sections of the draft guideline documents addressing Microbiological Quality include the suggestion that "all surface water sources should be filtered." Suggesting that "all surface water sources should be filtered" does not take into account situations where the source water is of high quality and is well protected from contamination. Both the draft Health Canada Guideline on Turbidity (published May 2002) and United States Environmental Protection Agency regulations identify situations where filtration of surface waters is not needed and the new draft guideline documents should be modified accordingly. The construction and maintenance of filtration systems demands a significant expense, and we hope to avoid the construction of unnecessary facilities that may draw financial resources away from areas that are a higher priority from a public health perspective.
Trihalomethanes in Drinking Water
The new draft guideline document on Trihalomethanes includes the following proposed guideline:
"Utilities should make every effort to achieve the lowest concentrations possible without compromising the effectiveness of water disinfection"
This proposed guideline needs to be qualified, or deleted, as it provides an open ended expectation that utilities "should make every effort" to reduce Trihalomethanes "to the lowest concentrations possible" even if Trihalomethane levels are well below the proposed maximum acceptable concentration (of 0.1 mg/L). Without qualification, this guideline could be misinterpreted by some regulators, possibly resulting in unnecessarily burdensome financial impacts to water utilities and/or negative environmental impacts associated with alternative disinfectant chemicals.
FINANCIAL IMPLICATIONS
If the City of Vancouver and GVWD comments are not adopted by Health Canada in the new guidelines, there is potential for significant financial expenditures for projects that may not represent the best value for Vancouver rate payers.
CONCLUSION
This report provides comments on the new Health Canada draft water quality guideline documents and recommends the comments be conveyed to the Province and Health Canada.
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